Deep Dives

The Fair Credit Reporting Act (FCRA) impacts every aspect of a U.S. consumer’s life. Consumer reports are obtained by lenders, employers, landlords, and even utility companies, impacting the cost of credit and everyday services, as well as the ability to obtain employment or access housing. It is the subject of regular litigation as well as regulatory enforcement action and thus deserves particular attention. If your business currently obtains consumer reports or plans to obtain consumer reports as part of a new venture, how does the FCRA impact your business and what should you be thinking about?

Introduction  |  April 21, 2021
Fair Credit Reporting Act: Policy Check In – Permissible Purpose  |  May 6, 2021
When is it a Firm Offer of Credit?  |  June 17, 2021

The Bank Secrecy Act (BSA) is the United States’ most important anti-money laundering (AML) regulation that requires banks, money services businesses, FinTechs, and other financial institutions to assist U.S. government agencies to detect and prevent money laundering. To achieve compliance with BSA/AML, financial institutions must navigate a range of regulatory requirements which focus on reporting, liaising with authorities, and building internal anti-money laundering controls. That process involves important considerations that this series will address, such as:

• The scope of BSA and whom it applies to
• Drafting sound BSA/AML policies and procedures
• BSA, Customer Identification Program (CIP), and Office of Foreign Assets Control (OFAC) for “loan or finance companies”
• Suspicious Activity Reports (SARs) for marijuana-related businesses

Introduction  |  September 2, 2021
Podcast: BSA, OFAC, KYC, and CIP – What do they mean to me?  |  September 15, 2021
Webinar: 5 Pillars of BSA Policies and Procedures  |  September 16, 2021

The world of decentralized finance, blockchains, virtual and cryptocurrency have grown exponentially in recent years. Many financial institutions are looking to enter or expand their operations in the digital economy, but the regulatory environment gives many pause. Many organizations think that because they don’t directly engage in mining cryptocurrency, they are not subject to laws regarding DeFi activity, but there’s much more to it than that. From licensing and vendor management to money transmission and payment rails, where do my obligations begin?

Introduction: Video  |  August 9, 2022

Introduction: Podcast | August 22, 2022

Primer: Understanding DeFi: Words Have Meaning, But What Do They Mean? | September 8, 2022

Podcast: DeFi and Digital Assets: What do the UCC Amendments Mean for Business Transactions? | September 19, 2022

Webinar: When Is Virtual Currency Treated as Currency Under State Law | September 30, 2022